Authorities Having Jurisdiction ultimately will decide whether a project is approved or falters. Having a detailed operating procedure certainly will not hurt.
March 1, 2006
I have 28 years in the structured cabling business and 10 years as a firestop manufacturer so I am confident I can help you if you are going to route cables through fire-rated barriers.
To begin with, all inspectors, known as Authorities Having Jurisdiction (AHJs), carry the burden of being the individual who must approve or reject someone’s work or product.
Naturally, it is important that we are able to identify who the AHJ is. The American National Electrical Code, for example, states that the AHJ is the local, state or federal official designated and responsible for approving equipment, installation or procedure.
In essence, the AHJ assumes some liability when he or she makes a decision. This liability, in today’s lawsuit happy environment, requires the AHJ to proceed with more caution than in the past.
It is a fact that the AHJ may even be someone other than a typical building inspector. The definition in the NEC book clearly states that insurance inspectors or risk assessment agents are AHJ’s.
A building owner or designated agent may assume the role of the AHJ. In the building industry, an OSHA inspector could be the AHJ.
Develop a working plan
Since you need to give an AHJ what they want, I suggest developing a standard operating procedure for dealing with firestopping cabling.
Most inspectors are surprised when an installer makes an effort to properly firestop cables much less have a plan in place to do it professionally. The point here being that just because firestop is not in the scope of work, it does not mean that it does not have to be done.
After establishing which AHJ you will approach, confirm the rating of the fire barrier. Be sure to find out if there are other requirements in addition to the typical “F” rating. You will need to meet any “T” or “L” ratings as well. The F (flame) and the T (temperature) ratings are measured in the amount of time the barrier will resist a fire.
The higher the rating, the more robust the barrier is. The L rating (cold gas) is measured by how much gas will pass through the barrier during a fire prior to the flames reaching the barrier.
The lower the L rating, the better the seal. The best L rating for a penetration is 0. This means no gas has passed through the barrier for the duration of the F and T rating.
Watch for more L ratings in the future. The F and T ratings are intended to save property. The L ratings are intended to save lives.
Once the ratings for a barrier to be penetrated have been established, seek a “tested” penetration system for your application. You will need to meet or exceed the barriers rating with your selection.
Manufacturers will help you with this task. Also, be sure the product you select has been listed for use in Canada by an independent testing facility.
Print out the listing as you will need to use it for your submission to the AHJ seeking pre-approval. Yes, ask permission. If we ask permission and the AHJ pre-approves our method, then we are approved.
Keep written records
In addition, always keep all written records of the pre-approval process indefinitely.
If the AHJ does not approve your system, he/she will tell you why and you can take steps to respond to his/her concerns before you ever step foot in the building.
Once your proposal has been pre-approved, all you need to do is to ensure that the selected system is installed to the limitations of the test and assembly procedure supplied by the manufacturer.
Document and keep a digital pictorial of all the penetrations made by your group. If others disturb or overfill your penetration system, you will easily be able to go to your alpha-numerical installation pictorial to show an AHJ how it was when you left it.
This procedure has created new opportunities for those who properly ID and document their penetrations to a database of installations. Many times these opportunities reveal themselves in an inspection when others have disturbed your seal.
Because you are in the business and have shown you properly sealed the barrier, the cables installed by others will need to be removed from your penetration system and placed in their own.
It will be a task that you have already proven you are qualified for. Keep the pictorial updated as each penetration is re-entered.
Be sure to get close enough to see the ID number as well as the number of cables allowed on the documentation label.
Many facilities do this to track availability of space in existing fire stop systems in a given barrier.
This practice will eliminate any unnecessary parallel penetrations.
Finally, acquire factory certification training for your installers. Nothing makes an inspector happier than a fully qualified individual who has formal and “verifiable” factory training.
It makes it easy for an AHJ to check your qualifications and make pre-approvals based on your level of training.
Your certificate should accompany the submittal documents when you submit your AHJ consideration request. Most major manufacturers of firestop material or systems offer certification training and many offer it free of charge.
Certification training allows for effective communications between a manufacturer of a tested system and the installer who will pit it in. As changes and upgrades are made, you will be in the loop.
Many firestop companies also have contractor programs allowing product to be purchased direct at contractor pricing for certified technicians.
In summary, it is much easier to seek permission rather than ask for forgiveness in the event of a blaze breaks out.
I have helped many installation companies out of some difficult situations by advising them not to ever argue with an AHJ.
It could turn into a bad situation, one that may result in you being removed from a job and the building being red-tagged and evacuated until what you have done to upset the AHJ has been corrected.
Remember that AHJs have a responsibility to do what is necessary to keep buildings safe and fire barriers up to code. To that end, they will use their authority to ensure you do the right thing.
Mike Tobias is the CEO of Unique Fire Stop Products Inc. in Robertsdale, Ala. He can be reached at firstname.lastname@example.org.